The Federal Circuit, in SIGRAY, INC. V. CARL ZEISS X-RAY MICROSCOPY, INC., 137 F.4th 1372 (Fed. Cir. May 23, 2025), reversed the PTAB's anticipation holding and remanded the PTAB's obviousness decision. The Federal Circuit found that the PTAB implicitly narrowed the magnification limitation by concluding that Sigray failed to prove Jorgensen shows enough beam divergence for magnification. The implicit narrowing was established by the PTAB's discussion contemplating some amount of divergence and reliance on expert testimony explaining that Jorgenson taught "essentially parallel" beams with "no meaningful divergence." The CAFC stated that claim language should be interpreted according to its plain and ordinary meaning and that the Jorgensen system inherently resulted in magnification greater than 1 as claimed, even if slight or undetectable.
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